Privacy Policy
Last updated: March 2026
1. Data Controller
The data controller for this platform is:
Yanyi FZ-LLC
Al Hamra Industrial Zone-FZ
FOB50677 Ras Al Khaimah, United Arab Emirates
Email: info@manualworks.de
2. Data We Collect
2.1 Account Data
When you register and use the platform, we collect:
- Email address (for authentication and communication)
- First and last name
- Password (stored encrypted with bcrypt, never in plain text)
- Organization data (company name, address, if provided)
2.2 Usage Data
- Uploaded documents (Word files) and their text content
- Generated translations and edits
- Glossary entries and Translation Memory data
- Token consumption and transaction history
- Audit logs (user actions with timestamps)
2.3 Technical Data
- IP address
- Device type and browser (User Agent)
- Refresh token metadata (device, IP) for session management
3. Purpose of Data Processing
| Data | Purpose | Legal Basis |
|---|---|---|
| Account data | Registration, login, account management | Contract performance |
| Documents & translations | Delivery of translation services | Contract performance |
| Token usage & transactions | Billing and balance management | Contract performance |
| Audit logs | Accountability, security | Legitimate interest |
| IP address, device data | Security, abuse prevention, session management | Legitimate interest |
| Email address | Verification, password reset, invitations, status notifications | Contract performance |
4. Third-Party Data Processors
We use the following service providers who may have access to personal data:
| Provider | Purpose | Data Shared |
|---|---|---|
| Stripe (USA) | Payment processing | Payment details, email, organization reference |
| Brevo / Sendinblue (EU) | Email delivery (SMTP relay) | Email address, name (within email content) |
Note on AI processing: The AI models used for translation are self-hosted on dedicated hardware in a Hetzner data center in Germany. Your document text never leaves the EU and is not shared with third-party providers. Data is used exclusively for generating your translation drafts and is not used for training AI models.
5. Data Storage and Security
5.1 Storage Location
The platform operates on dedicated servers in Germany. Documents and user data are stored in a PostgreSQL database and an S3-compatible object store on the same server.
5.2 Security Measures
- Encrypted transmission via TLS/SSL (HTTPS)
- Passwords are stored hashed with bcrypt
- JWT-based authentication with short-lived access tokens (30 min)
- Account lockout after 5 failed login attempts (15 min)
- Organization-based data isolation (multi-tenant)
- Audit logging of all security-relevant actions
6. Data Retention
| Data | Retention |
|---|---|
| Account data | Until account deletion |
| Documents & translations | Until deleted by user or account deletion |
| Transaction data | 10 years (legal retention requirement) |
| Session tokens (refresh) | 30 days |
| Email verification tokens | 7 days |
| Password reset tokens | 24 hours |
7. Cookies and Tracking
manualworks uses only technically necessary cookies and local storage mechanisms (localStorage) for session management and authentication. We do not use tracking, analytics, or advertising cookies. There is no third-party user tracking.
8. Your Rights
You have the right to:
- Access — Request information about personal data we hold about you
- Rectification — Correct inaccurate data
- Erasure — Delete your data, where no legal retention obligations apply
- Restriction of processing — Temporarily restrict data processing
- Data portability — Export your data in a common format (the platform supports export of documents, translations, TM, and glossaries)
- Objection — Object to processing based on legitimate interests
Please direct requests to: info@manualworks.de
9. International Data Transfers
Through the use of Stripe (USA) as a payment provider, payment data may be transferred to the United States. Stripe is subject to appropriate data protection agreements. We ensure that transfers are based on suitable safeguards (e.g., Standard Contractual Clauses).
AI-based processing of your documents takes place exclusively on our own servers in Germany. Document content is not transferred to third countries.
10. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy as needed, for example when platform features or legal requirements change. Material changes will be communicated by email.
Yanyi FZ-LLC — Al Hamra Industrial Zone-FZ, FOB50677 Ras Al Khaimah, UAE
Contact: info@manualworks.de